Protecting Consumer Privacy in an Era of Rapid Change: a Proposed Framework for Businesses and Policymakers

The comments here respond to the questions posed in the Federal Trade Commission’s draft privacy report. CDT believes the draft report provides a strong foundation for a privacy protection framework and we applaud the FTC’s excellent work. We are especially pleased to see that the FTC has embraced the full range of the Fair Information Practice Principles and recommended that those principles be applied to all companies that collect, use, and maintain consumer information, both online and offline. Fundamentally, CDT believes that this framework can only be accomplished across the entire ecosystem through baseline privacy legislation, and we urge the FTC to endorse that approach as the appropriate means to implement a new privacy protection framework in its final report.